In its notice about upcoming rules to implement the “Cadillac” tax on high-cost health plans in 2018, the IRS laid out its thinking related to several areas of the health care reform law's excise tax.

They include:

Employer on-site medical clinics: On-site clinics that provide only minor services would not be considered group plans and would be excluded in excise tax calculations. But the IRS wants comments on whether on-site clinics that provide immunizations and treat workplace injuries should be excluded from the calculations.

Self-insured dental and vision plans: The health care reform law already excludes insured dental and vision plans when calculating the excise tax. The IRS said it is considering extending that exclusion to self-insured dental and vision plans.

Age and gender adjustments: “Comments are requested on whether it would be desirable and possible to develop safe harbors that appropriately adjust dollar limit thresholds for employee populations with age and gender characteristics that are different than those of the national workforce,” the IRS said.

High-risk professions: The IRS also sought comments on allowing plan costs above the excise tax cost trigger of $10,200 for single coverage and $27,500 for family coverage in 2018 for high-risk professions, such as law enforcement, firefighters and paramedics, and how an employer would determine if most workers in a plan are engaged in a high-risk profession.